NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam0081OpenMr. Carl W. Ruegg, Selma Trailer & Manufacturing Company, P. O. Box 120, Selma, CA 93662; Mr. Carl W. Ruegg Selma Trailer & Manufacturing Company P. O. Box 120 Selma CA 93662; Dear Mr. Ruegg: Thank you for your letter of May 2, 1968, which included additiona information for certification under Public Law 89-563 and your comments.; You will note that Federal Motor Vehicle Safety Standard 108 does no restrict the height of the identification lamps from the roadway. You may find it suitable to mount these lights at a lower level than indicated in your illustrations.; With respect to the requirements of Standard No. 108, I must point ou that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.; I am enclosing a copy of the National Traffic and Motor Vehicle Safet Act of 1966 which defines the vehicles to which it applies.; Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam5283OpenMr. Matt Gerrity 7624 Rohrer Dr. Downers Grove, IL 60516; Mr. Matt Gerrity 7624 Rohrer Dr. Downers Grove IL 60516; "Dear Mr. Gerrity: This responds to your letter, forward to us o December 9, 1993, by Representative Harris W. Fawell, regarding the removal of the air bag in your 1990 Coupe de Ville. Because you have a physical handicap, you had your vehicle modified by the installation of a hand control system over the steering wheel. You are concerned that, in the event the air bag should activate, the steering device would probably pop off causing serious injury. You also stated that dealers and other mechanics are reluctant to disconnect the air bag because of Federal law. As discussed below, in certain limited situations, the National Highway Traffic Safety Administration (NHTSA) has exercised its discretion in enforcing our regulations to provide some allowance when making modifications to accommodate the special needs of persons with disabilities. While the disconnection of an air bag by a dealer or motor vehicle repair business would ordinarily be a violation of Federal law, this is to advise you that this agency would not institute enforcement proceedings against a dealer or repair business that disconnected the driver side air bag in your vehicle. If you show this letter to your dealer or mechanic, you should be able to get this work performed. By way of background information, NHTSA is authorized to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and new items of motor vehicle equipment. Manufacturers are required by the National Traffic and Motor Vehicle Safety Act (Safety Act) to certify that their products conform to our safety standards before they can be offered for sale. Manufacturers, distributors, dealers and repair businesses modifying certified vehicles are affected by 108(a)(2)(A) of the Safety Act. It prohibits those businesses from knowingly rendering inoperative any elements of design installed on a vehicle in compliance with a safety standard. Removal or disconnection of an air bag by any of the named commercial entities would violate the 'render inoperative' prohibition, since air bags are installed to comply with Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection. However, in certain situations where a vehicle must be modified to accommodate the needs of a particular disability, NHTSA has been willing to consider any violation of 108(a)(2)(A) a purely technical one justified by public need, and indicated that it would not institute enforcement proceedings. We will take this position for the specific factual situation cited above. We caution, however, that only necessary modifications should be made. For example, S4.5.2 of Standard No. 208 requires a readiness indicator for an air bag system which is clearly visible from the driver's seating position. After the air bag is removed, this indicator would show that the air bag system is not operative. The readiness indicator should not be modified, so other drivers who may expect an air bag will be aware that the air bag is not functional. I would also like to caution your dealer or mechanic to contact the vehicle manufacturer concerning the proper procedure for any air bag disconnection as this procedure could cause it to deploy and injure the mechanic. As a final caution, I note that the purpose of the 'render inoperative' provision is to ensure, to the degree possible, that current and subsequent owners and users of a vehicle are not deprived of the maximum protection afforded by the vehicle as newly manufactured. Your letter states that you would have the air bag reconnected before selling the car. I urge you to have this work performed so that future users of the vehicle will have the protection the air bag affords. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel cc: Representative Harris W. Fawell United States House of Representatives 2342 Rayburn House Office Building Washington, DC 20515-1313"; |
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ID: aiam2546OpenMr. Dick Rechlicz, Executive Secretary, Wisconsin School Bus Association, Box 403, Brookfield, WI 53005; Mr. Dick Rechlicz Executive Secretary Wisconsin School Bus Association Box 403 Brookfield WI 53005; Dear Mr. Rechlicz: This responds to your March 5, 1977, letter asking for a interpretation concerning the definition of school bus. In particular you ask how the National Highway Traffic Safety Administration determines the seating capacity of a motor vehicle which in turn determines whether that vehicle will be considered a school bus for purposes of our regulations.; You are correct in your interpretation that a van designed to carr fewer than 10 passengers may transport children to or from school and need not comply with the new school bus safety standards. The NHTSA determines the seating capacity of a motor vehicle by the number of designated seating positions in the vehicle. The term 'designated seating position' is defined in Part 571.3 of our regulations (49 Code of Federal Regulations) to mean: '...any plan view location intended by the manufacturer to provide seating accommodation while the vehicle is in motion for a person at least as large as a 5th percentile adult female, except auxiliary seating accommodations such as temporary or folding jump seats.' Thus, as long as a van purchased for pupil transportation has fewer than 10 designated seating positions for passengers, it is not considered a school bus and need not comply with school bus safety standards.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5329OpenMr. Perry McGlothan Quality Assurance Test Specialist Century Products Company 9600 Valley View Road Macedonia, OH 44056; Mr. Perry McGlothan Quality Assurance Test Specialist Century Products Company 9600 Valley View Road Macedonia OH 44056; Dear Mr. McGlothan: This responds to your letter to me about the hea impact protection and protrusion limitation requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, Child Restraint Systems. We received under separate cover the three child seats you sent for illustration purposes, samples of Models 4560, 4590 and the STE 1000. You discuss in your letter a new method you would like to use to attach the head impact protection foam to the child restraint shell. The foam would be attached to the shell by means of two push-in pins, each 1/2 inch in length and with a 3/4 inch diameter head, as distinguished from the padding being glued to the shell as in the past. You stated that this change would better secure the foam padding to the shell and help your manufacturing process. You asked us whether the new method would meet the head impact protection requirement of S5.2.3 (for restraints recommended for children weighing less than 20 pounds) and the protrusion limitations of S5.2.4. As you know, the National Traffic and Motor Vehicle Safety Act establishes a self-certification system under which manufacturers are responsible for ensuring that their products comply with all applicable FMVSSs. We do not approve, endorse, or give assurances of compliance of any product. NHTSA may examine the manufacturer's certification in the course of any enforcement action. In response to manufacturers' requests for interpretations of the FMVSS's, we try, to the extent possible, to provide information that will help them make their determinations of compliance. However, these responses are based on information provided by the manufacturer, and is subject to the findings of actual compliance testing by the agency. Should the agency, in the future, examine production units of these models and detect an apparent noncompliance or defect, those results will control. You first inquire, 'Please advise as to compression deflection,' which we understand as asking whether S5.2.3.2 would permit you to secure the foam with the pins. S5.2.3.2 states that each system surface, except for protrusions that comply with S5.2.4, which is contactable by a dummy head must be covered with slow recovery, energy absorbing material with specified characteristics. As explained in the next paragraph, the pins we examined appear to satisfy S5.2.4. Further, the pins might not be contactable by the dummy head in Standard 213's dynamic test. However, whether they are contactable can only be determined in the standard's dynamic test. S5.2.4 requires that any portion of a rigid structural component within or underlying a contactable surface, or any portion of a child restraint system surface that is subject to S5.2.3 shall meet specified limits on height and radius of exposed edge. Based on our visual inspection, the pins we saw appear to be within those limits. Again, however, the Vehicle Safety Act places the responsibility for determining compliance in the first instance on you, the manufacturer of the child restraint. We still have the three seats that you sent us. We plan to dispose of them unless we hear from you. I hope this information is helpful to you. Should you have any further questions or need further information, please feel free to contact Walter Myers of this office at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2116OpenHonorable Jamie L. Whitten, House of Representatives, Washington, D.C. 20515; Honorable Jamie L. Whitten House of Representatives Washington D.C. 20515; Dear Mr. Whitten: This is in further reply to your letter of October 3, 1975, for Mr Charles Russell of WJLJ,regarding tire failures on ambulances in Tupelo, Mississippi.; Pursuant to the national Traffic and Motor Vehicle Safety Act of 1966 the Department's National Highway Traffic Safety Administration (NHTSA) has issued Federal Motor Vehicle Safety Standard No. 109, 49 CFR 571.109, which specifies performance and labeling requirements for new tires for use on passenger cars. Among the labeling requirements is that such tires must have their load ratings molded into or onto both sidewalls. Standard No. 119, 49 CFR 571.119, establishes similar requirements for new tires for use on trucks, buses, trailers, motorcycles, and multipurpose passenger vehicles (MPV's). The choice of standard applicable to a given tire depends on that tire's primary intended use. These standards apply to tires, and not to vehicles.; To ensure that new vehicles are equipped with proper tires, the NHTS has also issued Standard No. 110 for passenger cars and a proposed new Standard No. 120 that would apply to vehicles other than passenger cars. Briefly, Standard No. 110 requires each new passenger car to be equipped with tires which meet Standard No. 109 and which are sufficient load carrying capacity, as evidenced by the load ratings found on the sidewalls. As proposed, Standard No. 120 would require MPV's (including ambulances) to be equipped with tires which meet either Standard No. 109 or No. 119, and which are of sufficient load carrying capacity. In the case of Standard 119 tires, sufficiency of load carrying capacity would be calculated directly from the tires' load ratings. In the case of Standard 109 (passenger car) tires mounted on an MPV, sufficiency would be determined by dividing the tire load ratings by a 110 percent correction factor before comparing these ratings with the vehicle's weight ratings. The use of passenger car tires on new ambulances would thus not be prohibited by the new standard, provided this load rating correction factor is applied. This provision would recognize an established practice which has not been found to present a safety hazard. Passenger car tires generally provide a softer, more comfortable ride than truck tires, because the latter operate at a higher inflation pressures, and thus may even be more desirable on ambulances, provided they are of adequate load carrying capacity. The NHTSA expect to issue Standard No. 120 in the near future.; For your convenience, I am enclosing copies of Standards Nos. 109, 110 119, and the proposed Standard No. 120.; Sincerely, William T. Coleman, Jr. |
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ID: aiam2638OpenNoel C. Ice, Esq., Cantey, Hanger, Gooch, Munn, & Collins, 1800 First National Bank Building, Fort Worth, TX 76102; Noel C. Ice Esq. Cantey Hanger Gooch Munn & Collins 1800 First National Bank Building Fort Worth TX 76102; Dear Mr. Ice: This responds to your March 1, 1977, letter asking whether your client a company that manufactures, distributes, and sometimes installs air conditioners and cruise control units on automobiles prior to first purchase for purposes other than resale, must comply with the certification and other requirements of the National Highway Traffic Safety Administration (NHTSA).; Section 114 of the National Traffic and Motor Vehicle Safety Act o 1966 (the Act) (15 U.S.C. 1381, 1403) requires that motor vehicle and motor vehicle equipment manufacturers certify that each vehicle or item of equipment conforms to all applicable Federal motor vehicle safety standards. There are no standards applicable to air conditioners or cruise controls. Thus, your client would not be required to certify the equipment he manufactures.; Your client may, however, have certification responsibilities a prescribed in the regulation issued under Section 114 (49 CFR Part 567, *Certification) in his capacity as installer of air conditioners or cruise controls if such installation places him within the status of 'alterer,' as that term is defined in Part 567.7. This would occur if the installation of the equipment, prior to the vehicle's first purchase for purposes other than resale, either altered the vehicle's gross vehicle weight rating or gross axle weight rating or was the installation of a nonreadily attachable component.; It is unlikely that the installation of an air conditioning unit woul alter the gross vehicle weight rating (GVWR). GVWR is defined in 49 CFR Part 571.3 as 'the value specified by the vehicle manufacturer as the loaded weight of a single vehicle.' The installation of air conditioners or cruise controls may, however, constitute an installation of equipment which is not readily attachable or may exceed the gross axle weight rating. If this is the case, your client would have to comply with the requirements of Part 567.7. To ascertain whether the installation involves readily attachable components such factors as the intricacy of installation, and the need for special expertise or tools must be taken into consideration.; You ask whether your client would be required to comply with 49 CF Part 566, *Manufacturer Identification*. This part applies to manufacturers of motor vehicles and motor vehicle equipment to which a safety standard applies. Since no safety standards apply to the equipment manufactured by your client, he would not be required to comply with this regulation in his capacity as an equipment manufacturer. Further, the NHTSA has determined by interpretation that vehicle alterers need not comply with Part 566. Similarly, 49 CFR Part 568, *Vehicles Manufactured in Two or More Stages*, may not apply to your client, since the installation of an air conditioner or a cruise control would not make your client an incomplete vehicle manufacturer, an intermediate manufacturer, or a final stage manufacturer of vehicles as those terms are defined in the regulation (568.3). Your client might have responsibilities under Part 568.8 as a vehicle alterer, however.; You should note that if your client is considered an alterer, a defined in Part 567 or Part 568 he would be considered a manufacturer for purposes of notification and recall for defects or noncompliances resulting from his installations (the Act, Section 151 *et seq.).; If we can be of further assistance do not hesitate to contact us. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0605OpenMr. Louis Goldberg, Product Manager - Industrial Mastics, Daubert Chemical Company, 709 Enterprise Drive, Oak Brook, IL, 60521; Mr. Louis Goldberg Product Manager - Industrial Mastics Daubert Chemical Company 709 Enterprise Drive Oak Brook IL 60521; Dear Mr. Goldberg: This is in reply to your letter of February 14, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to industrial deadeners and underbody coatings that you manufacture for use in motor vehicles. You describe three uses of these products: as an undercoating, a deadener, and an adhesive, and enclose three brochures, each describing a different product.; Standard No. 302 applies to motor vehicles, and from a lega standpoint, manufacturers of component parts are not subject to its requirements. As the completed vehicle must comply with the standard, however, vehicle manufacturers, on whom the burden of compliance does rest, must ascertain that components they use in their vehicles do meet the standard's requirements.; In this context, and with reference to your products, paragraph S4.2 o the standard (copy enclosed), requires that certain portions of vehicle components, including composites consisting of both surface and underlying materials, meet the specified burn-rate requirements. (A notice of proposed rulemaking, published May 25, 1971, also enclosed, would modify to some degree this provision.) Where composites are involved, compounds used between the layers of the composite are required to meet the requirements as part of the composite. Thus, while we cannot make an exact determination from the general descriptions in your letter, it is quite possible that when your products are used as deadeners or adhesives they would appear in composites that are required to meet the standard. Whether the material actually comes into contact with passengers is not a criterion.; At the same time, under the standard only completed vehicles will b tested. We note from the brochures you have enclosed that your materials are not flammable after drying. If this is the case, you should not have a problem with conformity, as your material will be tested, where appropriate, in what we would assume would be its dry state.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1917OpenHonorable Alan Cranston, United States Senate, Washington, D.C. 20510; Honorable Alan Cranston United States Senate Washington D.C. 20510; Dear Senator Cranston: #I am writing in response to your letter o April 14, 1975, in which you requested information on Federal Motor Vehicle Safety Standard No. 106-74 (49 CFR Part 571.106-74) and its relation to the enclosed letter you had received from Mr. Thomas Z. Marshall of San Francisco. #Standard No. 106-74 specifies performance and labeling requirements of motor vehicle brake hose, brake hose end fittings, and brake hose assemblies. Because labeling applied to hose and end fittings cannot satisfactorily identify the manufacturer of an assembly made up of those components, S7.2 of the standard (by incorporating S5.2.4) requires certain assemblies to be labeled by means of a band. By identifying the manufacturer and the date of production, this permits both the enforcement of the standard's performance requirements and the tracing of defective assemblies. #Mr. Marshall appears to have misunderstood some aspects of the standard. While each manufacturer of brake hose assemblies must initially inform the NHTSA of the identifying designation he intends to use on his bands, these is no requirement that he keep records of assemblies made or send such records to this agency. In addition, the bands need not be metallic, but may be of other materials which are less expensive to produce. Mr. Marshall has correctly pointed out, however, that the standard in its present form specifies the same requirements for large manufacturers, repair shops, and individual truck owners. In recognition of the burdens thus imposed on a person who manufactures only a small number of assemblies, the NHTSA proposed an amendment of the definition of brake hose assembly, to exclude certain assemblies from the requirements of the standard (40 Fr 8962, March 4, 1975, copy enclosed). We expect to act on that proposal in the near future. #Sincerely, James C. Schultz, Chief Counsel; |
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ID: aiam5407OpenMr. Walter Lavis 2467 Rt. 10 Bldg. 3 Apt. 7B Morris Plains, NJ 07950; Mr. Walter Lavis 2467 Rt. 10 Bldg. 3 Apt. 7B Morris Plains NJ 07950; "Dear Mr. Lavis: We have received your letter of June 6, 1994, wit respect to your 'Saf-T-Flec' reflectors. You say that you have been informed by a NHTSA representative that 'using the standard DOT approved reflector tape would allow the use of my reflector for the trucking industry.' Judging from the red, white, and amber samples you have enclosed, your 'reflectors' appear to be retroreflective tape which adheres to a semicircular aluminum base and is intended for vertical mounting on the side and back of vehicles. Several potential customers have asked whether your concept was 'DOT approved', and you have asked for a reply. The Department of Transportation has no authority to 'approve' items of motor vehicle equipment. We advise inquirers whether manufacture or use of any particular item of equipment is prohibited or permitted under the Federal motor vehicle safety standards and associated regulations. However, if an item is deemed permissible, this must not be represented as 'approval' by DOT. Your letter is somewhat unclear as to the intended use and market for Saf-T- Flec. The fact that you have enclosed a highlighted copy of S5.1.1.4 leads us to believe that one application you envision for Saf-T-Flec is as a substitute for original equipment side reflex reflectors. This substitution is permitted if the reflective material conforms to Federal Specification L-S- 300 (September 7, 1965) and, as used on the vehicle, meets the performance standards of SAE Standard J594f Reflex Reflectors, January 1977. Accordingly, if your red and amber samples meet these two requirements, they may be used as the side front, intermediate, and rear reflex reflectors that Tables I and III require on trucks and trailers. However, Standard No. 108 does not allow sheeting material to be used on the rear of vehicles in lieu of reflex reflectors. What if your reflectors do not meet the two specifications listed above? In this instance, they may be used as supplementary side reflectors to the reflectors that are required by Standard No. 108, and you may employ amber devices for this use as well as red and white. As supplementary equipment, they are subject to the Federal restriction only that they not impair the effectiveness of the required reflex reflectors. We do not believe that additional reflectors would have this effect. Supplementary lighting equipment such as additional reflectors is subject to the laws of the individual states. We are not able to advise you as to their acceptability under state laws. The American Association of Motor Vehicle Administrators (AAMVA) provides opinions on state law. AAMVA's address is 4600 Wilson Blvd., Arlington, Va. 22203. As you may know, S5.7 of Standard No. 108 requires red and white retroreflective material to be applied to the side and rear of large trailers that have been manufactured since November 30, 1993 (those whose overall width is 80 inches or more and whose GVWR is more than 10,000 pounds). This material may be retroreflective sheeting or reflectors. If sheeting is used, it must meet the photometric specifications of Figure 29. If reflectors are used, they must conform to SAE J594f, and provide specified minimum millicandela/lux at specified light entrance angles. Your initial question indicates that you may be interested in marketing Saf-T-Flec for use as a substitute for the conspicuity materials that conform to Standard No. 108. Manufacturers of conspicuity sheeting certify it with the material in a flat vertical plane (as evidenced by the DOT-C2 marking on your white sample). We have reservations whether the curved red and white Saf-T-Flec devices could meet the photometric specifications of Figure 29, for sheeting, or J594f and the millicandela/lux specifications of S5.7.2.1(b) or (c) for reflectors. Amber is not one of the specified colors for conspicuity treatment, and could not be used as a substitute. I hope that this answers your questions. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2268OpenHonorable Herman E. Talmadge, Chairman, Committee on Agriculture and Forestry, United States Senate, Washington, DC 20590; Honorable Herman E. Talmadge Chairman Committee on Agriculture and Forestry United States Senate Washington DC 20590; Dear Mr. Chairman: This is in response to your letter of April 1, 1976, forwardin correspondence from Mr. James A. Graham concerning the recently issued Part 581 bumper standard.; On March 4, 1976, the National Highway Traffic Safety Administratio (NHTSA) published a Federal bumper standard (41 FR 9346, 49 CFR Part 581) under the authority of Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The standard, effective September 1, 1978, specifies limitations on damage to non-safety related as well as safety-related vehicle components in low-speed collisions. Several manufacturers, including Gulf and Western Manufacturing Company, have filed petitions for reconsideration of the standard in conformance with NHTSA rulemaking procedures (49 CFR 553.35).; It is NHTSA's policy to issue a notice of action taken on petitions fo reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Mr. Graham in his letter.; I assure you that Mr. Graham's comments and the information containe in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.